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On January 10, 2024, the United States Attorney’s Office for the Southern District of New York (“SDNY”) introduced the SDNY Whistleblower Pilot Program (“Pilot Program”), aimed at encouraging individuals to disclose information about specific criminal offenses, particularly urging them to do so early and voluntarily. In return for their cooperation, SDNY will enter into a non-prosecution agreement (“NPA”) if certain conditions are met.
In a long overdue move to fill a perceived gap in U.S. law, this year’s National Defense Authorization Act included a new law that will finally criminalize the solicitation of bribes by foreign officials.
Earlier this month, a federal judge vacated two convictions related to the Department of Justice’s (“DOJ”) investigation into corruption in international soccer, widely known as the “FIFA Case.”
Enforcement of corporate crimes, which languished for two years during the COVID-19 pandemic, will grow more vigorous this year and may be accompanied by significantly tougher penalties, partners with Vinson & Elkins’ (“V&E”) Government Investigations & White Collar Defense practice say.
In a dramatic departure from prior practice, the U.S. Department of Justice (“DOJ”) recently released its second Opinion Procedure Release (“OPR”) in the last two years, following a half-decade of dormancy, and perhaps responding to criticism from the business community, DOJ actually provided actionable and immediate guidance to a company facing imminent harm.
Partners Palmina M. Fava in Vinson & Elkin’s New York City office and Fry Wernick, as well as associates Brian L. Howard II and Peter T. Thomas, all in the firm’s Washington, D.C. office, joined Natura & Company’s Group Chief Legal and Compliance Officer, Itamar Gaino Filho, and Group Vice President of Ethics & Compliance, Richard P. Davies, to author a new chapter on the Foreign Corrupt Practices Act (FCPA) for Thompson Reuters’ Successful Partnering Between Inside and Outside Counsel.
Foreign Corrupt Practices Act Enforcement Leaders at the DOJ and SEC Signal Increased Enforcement, an Upswing in Coordinated Investigations and Resolutions, and a Focus on Individual Actors to Dismantle Corporate Wrongdoing